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Privacy Policy

This Privacy Policy (the "Policy") is developed in accordance with the requirements of the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data, taken by Limited Liability Company "TULIDS" (hereinafter referred to as the "Operator").

1.1. The Operator sets as its main goal and condition of its activity the observance of the rights and freedoms of a person and a citizen when processing his/her personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Policy applies to all information that the Operator can obtain about the website visitors https://www.2leads.com.

1.3. Using the services of the website https://www.2leads.com means the User's unconditional consent to this Policy and the specified conditions of personal data processing; in case of disagreement with these conditions, the User should refrain from using the services of the website https://www.2leads.com.

2. Key concepts used in the Policy

2.1. Automated processing of personal data processing of personal data using computer equipment.

2.2. Blocking of personal data temporary cessation of personal data processing (except for cases when processing is necessary for clarification of personal data).

2.3. Website a collection of graphic and information materials, as well as computer programs and databases that ensure their accessibility in the Internet under the domain name https://www.2leads.com.

2.4. Information system of personal data a collection of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data any action (operation) or a set of actions (operations) performed with the use of automation facilities or without the use of such facilities with personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator a state authority, a municipal authority, a legal entity or a natural person who independently or together with other persons organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.8. Personal data any information that directly or indirectly relates to a specific or identifiable User of the website https://www.2leads.com.

2.9. Personal data allowed for distribution personal data access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as the personal data allowed for distribution).

2.10. User any visitor of the website https://www.2leads.com.

2.11. Provision of personal data actions aimed at disclosure of personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data any actions aimed at disclosure of personal data to an unlimited number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks or provision of access to personal data in any other way.

2.13. Transborder transfer of personal data transfer of personal data to a foreign state authority, a foreign natural person or a foreign legal entity.

2.14. Destruction of personal data any actions as a result of which personal data are destroyed irretrievably and cannot be restored in an information system of personal data and/or material media of personal data are destroyed.

2.15. Cookie file a small file used to store the settings of website view. During the first visit to the website, this file is downloaded via the browser. When visiting the website again from the same device, the browser may check the presence of the associated cookie file (i.e. containing the website name) and use the data of this file to send it back to the website. This allows the website to determine that the website has been visited from this browser before and, in some cases, to change the displayed content.

3. Basic rights and duties of the Operator

3.1. The Operator has the right:

  • to obtain from the personal data subject reliable information and/or documents containing personal data;
  • if the personal data subject revokes their consent to the processing of personal data, the Operator may continue to process personal data without the consent of the personal data subject in cases provided for by the Personal Data Law;
  • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged:

  • to provide the personal data subject with information about the processing of their personal data at their request;
  • to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
  • to respond to the appeals and requests of personal data subjects and their authorized representatives in accordance with the requirements of the Personal Data Law;
  • to report to the authorized body for the protection of the rights of personal data subjects the necessary information within 30 days from the date of receipt of such a request;
  • to publish or otherwise ensure unrestricted access to this Policy in relation to the processing of personal data;
  • to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unauthorized actions in relation to personal data;
  • to stop the transfer (distribution, provision, access) of personal data, to stop the processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • to fulfill other duties provided for by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right:

  • to obtain information about the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and does not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • to demand from the operator the clarification of their personal data, their blocking or destruction in case if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the declared purpose of processing, and also to take measures provided for by law to protect their rights;
  • to put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
  • to withdraw consent to the processing of personal data;
  • to appeal against the Operator's illegal actions or inaction to the authorized body for the protection of the rights of personal data subjects or in court;
  • to exercise other rights provided for by the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Also, on the website, there is a collection and processing of data about visitors (including cookie files) using internet statistics services (Yandex Metrica, Google Analytics, and others).

5.5. The above-mentioned data are combined under the general concept of Personal Data.

5.6. The Operator does not process special categories of personal data, including ethnic, national, political, religious or philosophical beliefs, or intimate life.

5.7. The processing of special categories of personal data, which are permitted for dissemination, is allowed with the consent of the personal data subject and under the conditions established by the Personal Data Law.

5.8. The User's consent to the processing of personal data, which is permitted for dissemination, is made separately from other consents to the processing of personal data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1 The User provides the Operator with consent to the processing of personal data, which is permitted for dissemination, directly.

5.8.2 The Operator is obliged to publish information about the conditions of processing, about the existence of prohibitions and conditions for the processing of personal data, which is permitted for dissemination, in the period of five working days from the date of receipt of the User's consent.

5.8.3 The transmission (distribution, provision, access) of personal data, which is permitted for dissemination, must be stopped at any time at the request of the personal data subject. The request must include the surname, name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data, the processing of which must be stopped.

5.8.4 The consent to the processing of personal data, which is permitted for dissemination, ceases to be valid from the moment the Operator receives the request, specified in paragraph 5.8.3 of this Policy.

5.9. The use of cookie files:

5.9.1. The website https://www.2leads.com uses its own cookie files, as well as third-party analytical tools, such as Google Analytics, Yandex Metrica, and call-tracking systems. These services help collect information about the use of the website, as well as collect additional information (about the field, age and preferences of users) and do it on an anonymous basis, which includes all visitors to the website.

5.9.2. The Operator uses cookie files that are set from multiple domains.

5.9.3. Some cookie files can make it easier to use the website https://www.2leads.com on subsequent visits, as the website can remember the user's preferences and provide content that is more relevant to the user's interests.

5.9.4. The cookie files used on the website may collect personal information about users

5.9.5. The Operator uses the following categories of cookie files:

1) Category 1 - strictly necessary cookie files. These cookie files are necessary for viewing the website and using its functions.

2) Category 2 - functional cookie files. These cookie files collect information about the use of the website, such as the most frequently visited pages. This information can be used to optimize the website and make it easier to navigate.

3) Category 3 - functional cookie files. These cookie files allow the website to remember the user's choice when viewing the website. The cookie files may also be used to track recommended products and video content to avoid repetition. The information provided by these cookie files does not allow identifying the user.

5.9.6. Control and deletion of cookie files. If you want to change the way your browser uses cookie files, including blocking or deleting cookie files from websites, you can do so at any time by using your browser settings. Disabling, deleting or refusing to receive cookie files may make some functions or features of the website unavailable. To manage cookie files, most browsers allow you to either accept or reject all cookie files, or accept only certain types of cookie files, or ask you what to do every time a website wants to save a cookie file. You can also delete cookie files that are already stored on your device using your browser.

5.9.7. To learn how to delete cookie files from a particular browser, use the built-in help of your browser or visit the website http://www.aboutcookies.org, which provides step-by-step explanations for controlling and deleting cookie files for most browsers.

5.9.8. For more information about cookie files, you can visit the following links: https://www.google.ru/policies/technologies/types/

6. Principles of personal data processing

6.1. Personal data processing is carried out on a legal and fair basis.

6.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.

6.3. It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.

6.4. Only personal data that correspond to the purposes of their processing are subject to processing.

6.5. The content and volume of personal data being processed correspond to the stated purposes of their processing. Excessiveness of personal data being processed in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data is ensured, their sufficiency, and, if necessary, their relevance to the purposes of personal data processing. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows to identify the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, side of which, beneficiary or guarantor is the personal data subject. Processed personal data are destroyed or anonymized upon achieving the purposes of their processing or in case of loss of need for achieving these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. The purpose of personal data processing is:

– informing and communicating with the User by sending electronic messages, sending notifications and information about the Operator's services;

– conclusion, execution and termination of civil law contracts;

– providing the User with access to services, information and/or materials contained on the website https://www.2leads.com;

- to provide the User with consulting services on the scope and specifics of the services offered by the Operator;

- to improve the quality of services and website services https://www.2leads.com;

- for statistical and analytical research in the field of advertising and website attendance https://www.2leads.com based on anonymized personal data;

- for other purposes not prohibited by the legislation of the Russian Federation.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending a letter to the Operator's e-mail address hello@2leads.com with the note «Refusal of notifications about new products and services and special offers».

7.3. Anonymized data of Users collected using internet statistics services are used to collect information about User actions on the website, improve the quality of the website and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

– the charter documents of the Operator;

– contracts concluded between the Operator and the personal data subject;

– federal laws and other regulatory legal acts in the field of personal data protection;

– the consent of Users to the processing of their personal data, permitted for distribution.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website hello@2leads.com or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (cookie files are saved and JavaScript technology is used).

8.4. The personal data subject independently makes a decision to provide their personal data and gives consent voluntarily, of their own free will and in their own interests.

9. Conditions for the processing of personal data

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a court ruling, the act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract, one of the parties to which, or the beneficiary or guarantor of which, is the personal data subject, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

9.6. The processing of personal data is carried out if the personal data subject has provided access to such data to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data).

9.7. The processing of personal data is carried out if such data is subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collecting, storing, transferring and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.

10.2. The User's personal data is never transferred to third parties, except in cases related to the execution of the current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address {' '} hello@2leads.com with the note «Update of personal data».

10.4. The period of personal data processing is determined by achieving the goals for which the personal data was collected, unless a different period is specified by contract or current legislation. The User can at any time revoke their consent to the processing of personal data by sending a notification to the Operator's email address hello@2leads.com with the note «Withdrawal of consent to the processing of personal data».

10.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obligated to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

10.6. The restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data, permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests, determined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing it.

10.8. The Operator stores personal data in a form that allows identifying the personal data subject, for no longer than is required for the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, side of which, beneficiary or guarantor is the personal data subject.

10.9. The termination of personal data processing may be caused by achieving the goals of personal data processing, the expiration of the consent of the personal data subject or the revocation of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transmits (distributes, provides, accesses), de-personalizes, blocks, deletes and destroys personal data.

11.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without it.

11.3. The Operator's employees have access to personal data only within the limits and to the extent necessary for the performance of their official duties related to the provision of services. All rules for working with personal data are strictly observed by all employees who have access to personal data.

12. Cross-border transfer of personal data

12.1. Before starting the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to which the personal data is being transferred provides reliable protection of the rights of personal data subjects.

12.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of his personal data and/or the execution of a contract, the party to which is the personal data subject.

13. Confidentiality of personal data

The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can get any clarifications on the issues related to the processing of their personal data by contacting the Operator through an electronic address hello@2leads.com.

14.2. Any changes to the personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is available on the Internet at https://www.2leads.com/ru/privacypolicy.